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case at docket No. 10766-00 for lack of prosecution.9 The Court
observed in Richards I that that response contained contentions
and arguments that the Court had found in the Court’s January 18,
2002 Order in that case to be frivolous and/or groundless. The
Court also found in Richards I that, despite the Court’s admoni-
tions in its January 18, 2002 Order in the case at docket No.
10766-00 about (1) the frivolous and/or groundless contentions
and arguments in Mr. Richards’ response to respondent’s motion to
dismiss for lack of prosecution in that case and (2) section
6673(a)(1), the brief that Mr. Richards filed in these cases on
February 15, 2002, contained statements, contentions, and argu-
ments that the Court found to be frivolous and/or groundless and
did not set forth any valid reason why the Court should not
dismiss for lack of prosecution the cases at docket Nos. 10765-00
and 10766-00.
With respect to the accuracy-related penalties under section
6662(a) at issue in the cases at docket Nos. 10765-00 and 10766-
00, the Court found in Richards I that respondent satisfied the
burden of production that respondent maintained respondent had
with respect to those penalties.
With respect to that part of respondent’s motion to dismiss
for lack of prosecution in each of the cases at docket Nos.
9Mr. Richards did not file a response to respondent’s motion
to dismiss for lack of prosecution in the case at docket No.
10765-00.
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